Frequent Questions

How is spent photographic fixer solution regulated when it is being recycled to recover silver?

Fixer solution itself is a spent material and regulated by 40 CFR Part 266, Subpart F, when reclaimed. A sludge precipitated from that solution is not a solid waste when reclaimed and is not subject to regulation pursuant to Part 266, Subpart F. 

The following memoranda provide additional information on the management of spent photographic fixer solution: 
Memo, Petruska to Stoneburner; August 16, 1995 (RCRA Online #13758
Memo, Petruska to McCoy; August 10, 1995 (RCRA Online #11914) 
Memo, Shapiro to Donovan; February 28, 1994 (RCRA Online #11814
Memo, Lowrance to Eschborn; July 16, 1990 (RCRA Online #11541)
Monthly Call Center Report Question; July 1985 (RCRA Online #12432

These memoranda are available in the RCRA Online database at the following URL: www.epa.gov/rcraonline.

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